” were themselves important al-Qaeda benefactors with direct ties to bin Laden dating from the
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and because senior Al Rajhi Bank officials
again by virtue of the public reporting concerning the
Al Rajhi Bank was aware at all relevant times that MWL
Al Rajhi Bank funneled its own zakat contributions to al-Qaeda
Khaled bin Mahfouz and Yassin al Kadi are referred to here is ahe “NCB Defendants.”)
and by virtue of the longstanding ties between senior executives of NCB
by virtue of the extensive public reporting concerning those
with specific awareness that those entities were supporting al-Qaeda.® At all times
typically through their own zakat charitable contributions to al-Qaeda’s
al-Qaeda’s partners in the financial sector operated covertly within its global infrastructure
including an account for bin Laden’s personal bodyguard
partnered with al-Qaeda by mamtaining accounts for al-Qaeda and by embedding
*° Al Shamal maintained accounts for Osama bin Laden and several other al-Qaeda officials
Al Shamal *45 and FIBS are referred to herein as the
it openly used Defendants Al Shamal Islamic Bank (“Al Shamal’”) and Faisal
during the period that al-Qaeda was headquartered in the Sudan under the protection of
its not any better. I dropped out of college because of you (and GM's) advice. Started working
which you could never understand I was even surviving off the pay I
make a better life and I am devastated these people found